Revenu Québec has made changes to its voluntary disclosure program. They apply to disclosure applications filed after December 17, 2025.

The first condition for benefitting from the program is that applications must be spontaneous. However, this condition has changed. To be considered spontaneous, applications must now be submitted before any audit or investigation has been initiated against the person (or a related person) regarding the information being disclosed. In the context of the program, audits or investigations are not limited to those conducted by Revenu Québec. They can also be conducted by a law enforcement agency, securities commission or other federally or provincially regulated authority.

Furthermore, the “general program” and “limited program” categories have been eliminated. Applications are now classified according to whether they are prompted or unprompted. Wash transactions and duties on the transfer of an immovable are still covered by the program and sorted under the new classification system.

Unprompted application

An application is considered unprompted in the following situations:

• It is made when there has been no communication (verbal or written) about an identified compliance issue related to the disclosure.
• It is made following an education letter or notice that offers general guidance and filing information related to a particular topic.

When an unprompted application is accepted:

• Revenu Québec will require payment of the duties related to all the omissions for all the years or periods for which the person did not meet their tax obligations.
• Penal proceedings and penalties will be waived for the disclosed facts.
• Interest will be charged as follows for the six calendar years preceding the year the disclosure takes effect:
  • 100% of the applicable interest will be charged for years or periods that are not prescribed
  • 50% of the applicable interest will be charged for years or periods that are prescribed

Prompted application

An application is considered prompted when it is made following verbal or written communication about an identified compliance issue related to the disclosure, which may include letters or notices to the person (excluding education letters) that do one or more of the following:

• identify a specific error or omission found in the person's account
• set a deadline for correcting an error or omission, where Revenu Québec expects the person to file a return or comply with their obligations

An application is also considered prompted if it is made after Revenu Québec has already received information from third-party sources regarding potential tax non-compliance by the person (or a related person).

When a prompted application is accepted:

• Revenu Québec will require payment of the duties related to all the omissions for all the years or periods for which the person did not meet their tax obligations.
• Penal proceedings and up to 100% of penalties will be waived for the disclosed facts.
• Interest will be charged as follows for the ten calendar years preceding the year the disclosure takes effect:
  • 100% of the applicable interest will be charged for the years or periods included in the first six calendar years preceding the year the disclosure takes effect
  • 50% of the applicable interest will be charged for the years or periods included in the four calendar years preceding the years mentioned in the last point

Whether prompted or unprompted, applications must meet all the conditions for the voluntary disclosure program, including that concerning the spontaneity of the application. Disclosures take effect on the date that Revenu Québec receives the duly completed and signed disclosure application.

A person can generally only benefit from the voluntary disclosure program once. A second application will be accepted only if it concerns a different situation or contains no evidence of intentional conduct.

Interpretation bulletin ADM. 4/R9, Le programme de divulgation volontaire, will be available soon (in French only) on the Publications du Québec website.